Tax advisory and planning in Thailand

Tax filing is execution: preparing and submitting monthly and annual returns (VAT, WHT, and the PND 50 annual CIT return). Tax advisory is design: structuring transactions and business decisions before they happen, so the tax result is both efficient and defensible. Most companies need both. Compliance files the returns correctly; advisory makes sure the structure behind those returns was right in the first place.

Very likely. Under the Emergency Decree on Top-Up Tax B.E. 2567 (in force since 1 January 2025), if your Thai effective tax rate falls below 15%, which a BOI tax holiday usually causes, a Qualified Domestic Minimum Top-Up Tax (QDMTT) applies. The BOI's 2025–2026 realignment introduced the Qualified Refundable Tax Credit (QRTC) for R&D, skills development, and productivity investments, to keep part of the incentive value under Pillar Two; its detailed rules are still being finalized. Plizz models your QDMTT exposure and QRTC eligibility before recommending whether to keep, restructure, or convert your BOI promotion.

Two rules matter. The Transfer Pricing Disclosure Form is mandatory for companies with related-party transactions and annual revenue of THB 200 million or more; it is filed with the CIT return within 150 days of year end. TP documentation (master file, local file, comparables study) has no strict revenue threshold, and when the RD asks for it you have 60 days to submit it (extendable, up to 180 days for a first request). Failing to file or deliver can cost up to THB 200,000 per failure, on top of any pricing adjustment, surcharge, or penalty from a TP audit. Most CFOs of companies above THB 200 million keep their documentation up to date every year rather than treating it as a one-off project.

It carries little weight. The burden of proof shifts to you: you must show arm's-length pricing without a documented basis. If the RD raises an assessment, you pay the tax shortfall plus penalties (up to 200% of the shortfall) and a 1.5% monthly surcharge. Prepare TP documentation when you set the price, not after the audit notice arrives.

Often, yes, through the Thailand-Singapore double tax agreement (signed 2015, in force since 11 January 2017). Under the treaty, the 15% domestic WHT on qualifying royalties falls to 5%, 8%, or 10%, depending on the type of intellectual property licensed. To use the treaty, the Singapore parent needs real substance, proper documentation, and a Certificate of Residence from the Inland Revenue Authority of Singapore, in hand before the payment. The position must be documented when you pay, not afterwards.

Three differences. Operating judgment: Plizz's founders, Benoît Meneau and Jérôme Le Louer, are former CFOs of international groups, so every recommendation is tested against its effect on your P&L, working capital, and audit, not just against the Revenue Code. Cost: our fees for comparable Thai work are typically well below Big-4 rates, and named senior partners stay on the engagement. Cross-border reach: as the Thai member firm of DFK International, we coordinate with tax advisers in more than 85 countries.

A freelancer usually gives a one-off opinion. A firm engagement comes with a documented working file, a named senior partner, professional liability insurance, and continuity if someone leaves. When the RD audits a position two or three years later, that working file is what defends it, not an old email thread.

Yes. RD audit and assessment defense is a separate add-on, quoted per case. Because we keep a working file for every position we advise, the audit response starts from the original analysis instead of being rebuilt under deadline pressure. We do not advise positions we are not prepared to defend.

Sometimes. Taxpayers can ask the RD for a written ruling on an uncertain issue, and a favorable ruling gives strong comfort. One caveat: Thailand's Advance Pricing Agreement (APA) program for transfer pricing is slower and less used than in the US, UK, or Japan, so informal guidance is more common. A ruling takes time, which must fit your transaction timetable. We tell you whether the certainty is worth the time and cost before recommending a request.